HomeMy WebLinkAbout04-4351JENNIFER LYNN HAGER,
PLAINTIFF
v.
JUSTIN D. UPDEGRAFF,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~( -~I3S~ C~~u~~~rr1Lr/1
CUSTODY ACTION
COMPLAINT FOR CUSTODY
1. The Plaintiff is Jennifer Lynn Hager who currently resides in
Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is Justin D. Updegraff who currently resides at 120
Ramblewood Drive, Etters, York County, Pennsylvania 17319.
3. Plaintiff seeks custody of the following child:
Name Present Residence ,A~e,
Riley Paige Updegraff Mechanicsburg, PA 9 months
4. The child was born out of wedlock.
5. The child is presently in the custody of Jennifer Lynn Hager
who resides in Mechanicsburg, PA.
6. During the past five (5) years, the child has resided with the following
persons and at the following addresses:
PERSONS
Plaintiff and Defendant
Plaintiff and Defendant
Plaintiff and Defendant
Plaintiff
ADDRESSES
1386 Bower Road
Shermansdale, PA
5076 Stacy Drive
Harrisburg, PA
120 Ramblewood Drive
Etters, PA
Mechanicsburg, PA
DATES
11 /15/03-5/28/04
5/29/04-7/9/04
7/10/04-8/11/04
8/11 /04-present
7. The Mother of the child is the Plaintiff. She is currently single.
8. The Father of the child is the Defendant. He is currently single.
9. The relationship of the Plaintiff to the child is that of mother.
The Plaintiff currently resides with herself and the minor child at the above
referenced address.
10. The relationship of the Defendant to the child is that of
Father. The defendant resides with himself at the above referenced address.
11. Plaintiff has not participated as a party or witness or in another
capacity in other litigation concerning custody of the child in this or another Court.
12. Plaintiff has no information of a custody proceeding concerning the
child pending in a Court of the Commonwealth or any other state.
13. Plaintiff does not know of a person not a party to the proceedings
who has physical custody of the child or claims to have custody or visitation rights
with respect to the child.
14. The best interest and permanent welfare of the child will be served
by granting the relief requested because mother has been the primary caregiver
and has played played an active and nurturing role in the development of
and the continued relationship would be in the best interests of the child.
15. Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the child have been
named as parties to this action.
WHEREFORE, Plaintiff, Jennifer Lynn Hager, requests the Court to grant her
shared legal and primary physical custody of the child.
Respectfully submitted,
NEALON ~ GOVER, P.C.
~~,~~~/~~- le~~~
James G. Nealon, III, Esquire
Attorney I.D. #46457
2411 North Front Street
Harrisburg, PA 17110
(717) 232-9900
VERIFICATION
I, JENNIFER LYNN HAGER, verify that the statements made in the foregoing
Complaint are true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to
authorities.
Date: ~)ay~~
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James G. Nealon, III, Esquire
NEALON & GOVER, P.C.
2411 North Front Street
Harrisburg, PA 17110
(717) 232-9900
JENNIFER LYNN HAGER,
PLAINTIFF
v.
JUSTIN D. UPDEGRAFF,
DEFENDANT
TO THE PROTHONOTARY:
IN THE COUIRT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-4351 CIVIL ACTION LAW
IN CUSTODY
PRAECIPE
Please mark the above captioned action discontinued.
Respectfully submitted,
NEALON & GQV,~~t. P.
By.
Date: !l~~`d ~f
James G. Nealon, III, Esquire
Attorney LD. #46457
2411 North Front Street
Harrisburg, PA 17110
(717) 232-9900
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OCT 0 S 2004
JENNIFER LYNN HAGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
~ CIVIL ACTION -LAW
. °I,';SI
JUSTIN D. UPDEGRAFF, NO. 2004 - T
Defendant IN CUSTODY
COURT ORDER
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AND NOW, this l day of October, 2004, tb.e Conciliator having appeared at
the Conciliation Conference and the parties not appeairing and it being told to the
Conciliator that the parties had reached an agreement, the Conciliator relinquishes
jurisdiction.
BY THE COURT,
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Hubert X. any
Custody nciliator
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